Holes in FracFocus

Ambiguous Data

Like proprietary claims, the records in this next group still appear in disclosures but they are simply not labeled or are labeled in a way that cannot be resolved to a single, specific chemical. That is, while they appear in the disclosure, companies do not give us enough information to understand their identity and therefore their toxicity.

For example, there are over 50,000 records with a recorded quantity but with no CASNumber given. Among these records, over 5,000 represent the carrier of the disclosure. In those disclosures, while the name implies some mix of water and other ingredients, there is no hint what those other ingredients might be. The mass of those records is at least 180,000,000,000 pounds. Other ambiguous identification includes CAS codes that are either obvious dummy codes (e.g., ‘0000-00-0’ or ‘xxxx-xx-x’) or codes for chemicals that are clearly wrong. [7]

When we cannot resolve these records at Open-FF, we label them as “ambiguousID.” For more details into this set of records, see the ambiguousID detail page. 

So, unlike the naïve expectation, there are clearly holes in the disclosure that we can see:

Invisible Holes

We saw above that Proprietary and Ambiguous classes are unidentified chemicals but we can see that they have been used. Another set of chemicals are injected in fracking operations that are not mentioned in FracFocus disclosures. We know they exist from evidence outside of FracFocus data. Included here are three classes that we know of: Safety Data Sheet omissions, water sources that contain more than water, and distillates.

Partial Ingredients List

Much of the chemical information in FracFocus is based on products’ Safety Data Sheets (SDS, sometimes called MSDS) that are compiled to comply with OSHA regulations. These documents, summarized here by OSHA, are primarily developed to inform workers who must work with these materials and to aid emergency response teams that might have to deal with spills or injuries. They are typically 3-15 pages and are usually found as PDF files. (Click here for a quick example. Note that the format of SDS/MSDS has changed in the last decade; section numbers may be different than the current format.)

FracFocus and the companies submitting chemical disclosures have re-purposed Safety Data Sheets from their worker safety/emergency responder origins to serve as an ingredient list for disclosures by using the SDS section that outlines the composition of the product. Because manufacturers of these products were already required to generate these SDS for each product, the SDS apparently became a handy source of ingredients for public disclosure. Below is the reported ingredient list from an example SDS for Plexsurf 251E by Chemplex:

Note here that there are three hazardous ingredients listed and that their CAS numbers are listed. The percent listed is also required but may be given as a range to allow the manufacturer to mask exact recipes or to allow for variability in the manufacturing process. FracFocus instructions stipulate that the upper level of the range should be used in their disclosures.

Clearly, this is an abridged list of what is in the product. At most, these three ingredients comprise 46% of the mass in the product, but as little as 32%. What is in that other 54-68% of the product? Often, only the manufacturer knows. Even operating companies, while they are responsible for the completeness of the disclosure, may never know all ingredients of the products they use (Horwitt & Teklemichael 2022).

Are these non-disclosed chemicals a problem? The SDS is not designed to be an exhaustive ingredient list unless all components are considered “hazardous.” Although it is possible that the non-identified percentage is benign, there are reasons to be suspicious of the absence. First, what may be considered non-hazardous in an occupational, or “intended use” setting (the main purpose of an SDS) may be problematic from an environmental perspective. Second, what is considered hazardous can change over time. For example, the status of PFAS chemicals has recently changed dramatically in the US. Third, while manufacturers are responsible for the SDS, they are also given significant leeway in declaring what is “hazardous” in their products and therefore visible in FracFocus disclosures.

Considering that PFAS surfactants have been mentioned in multiple places as highly effective in fracking (see Horwitt & Gottlieb, 2022), and yet rarely appear in FracFocus, it is reasonable to be suspicious that they may be used either as inert ingredients, deemed to be non-hazardous or hidden as proprietary ingredients. Because operators probably do not have full access to ingredient lists, the only way to verify that products are free of chemicals like PFAS may be analytical tests by independent labs.

Is the Carrier Really Just Water?

In the vast majority of fracking disclosures, water is the primary carrier of sand and other ingredients. This water often comprises 80% or more of the whole fracking fluid.

The source of that water may be nearby rivers, streams or lakes, from groundwater wells or even from municipal sources. And while the chemical identity reported in FracFocus for the vast majority of disclosures is simply “water” (CASRN: 7732-18-5), there is a disclaimer at the bottom of PDF disclosures that:

“Total Water Volume sources may include fresh water, produced water, and/or recycled water.”

This disclaimer reflects the reality that the wastewater generated by oil and gas extraction is often reused by operators. The volume of this “produced water” can be many times the volume of the oil or gas produced and is a nuisance by-product of the industry. This water can include “flow-back” materials from the original fracking slug. While this produced water has been used extensively in “enhanced oil recovery,” much of it is disposed of in waste injection wells. In recent years there has been a push to increase its use as part of the fracking carrier in newer wells. 

The actual composition of produced water is hard to quantify. Analysis of produced water is expensive and usually only tests for common markers such as mineral elements and known toxic materials (like “BTEX”, benzene, toluene, ethylbenzene and xylenes). Targeted analysis for other specific molecules such as PFAS chemicals is rarely performed and, because it is targeted, can still overlook materials that are important but not on the analyte list. 

Nevertheless, when analysis of produced water is performed, it is common to find a toxic cocktail (see Stringfellow and Camarillo, 2019; Neff et. al, 2011; Leuk & Gonsior, 2017. And see the EPA list from Danworth et al.), usually a combination of “natural” materials, such as hydrocarbons, radionuclides, and heavy metals as well as flow-back materials from fracking additives and the chemicals formed under the high pressure and temperature of the fracking process.

Therefore, produced water is much more than just water. However, even in FracFocus disclosures that explicitly report the use of produced water, the composition is typically just reported as water alone. For contrast,in one revealing set of about 120 FracFocus disclosures in 2018-19 in Texas, a few other materials are included as ingredients of produced water, most notably benzene at a concentration of 0.1% of the produced water. Because of the large volume of produced water used in these fracks, the quantity of benzene used in most of these wells was over 50,000 lbs. But for produced water, this reporting of more than just a water record is the exception, not the rule.

The bottom line is that the companies may be using water sources that include hazardous chemicals, and because these water volumes may be huge, the quantity of the hazardous hitchhikers will be very large as well. However, it is typical for none of that to make it into the disclosure.

What’s Hiding in That Mixture?

As mentioned in the introduction, to understand the risks associated with fracking chemicals, it is necessary to have a complete and well-defined list of materials. When a research paper is published that finds the toxicity of, say, naphthalene, researchers are reluctant to apply those results to other materials, even if it is closely related, simply because toxicity can be highly dependent on specific molecular characteristics. 

That need for a highly specific identity is a big obstacle with the next invisible “hole” in FracFocus. This third group consists of materials labeled by the Toxic Substance Control Act as “unknown or variable composition, complex reaction products or biological materials” (UVCBs). Within fracking operations, many UVCBs are petroleum distillates. 

For distillates, the unknown and variable part of their composition begins with the source material: crude oil is itself a UVCB and can contain hundreds of thousands of distinct chemicals. The distillation process is able to separate different groups of materials based on their chemical properties such as volatility. But these fractions are often approximate because of huge variation in the source material, the specific conditions during the distillation process and variability across refineries. (See Lai et al., 2022) 

How Common Are UVCBs in FracFocus?

UVCBs form a large group of materials in FracFocus disclosures: more than 300 materials are UVCBs, that is, 20% of all identified chemicals. Furthermore, among all additives (that is, ignoring water and sand), we find that UVCBs account for 15% of the mass across FracFocus. [10]

Considering a Single UVCB in FracFocus:

The difficulty with UVCB for users of FracFocus is that, while they are mixtures of many (often toxic) chemicals, they are represented by a single CAS number that obscures the component chemicals in the mixture. A common FracFocus material, “Heavy aromatic solvent naphtha (petroleum),” is identified by a single CAS number: ‘64742-94-5’. As its name suggests, it has a high percentage of aromatic compounds; that is, 64742-94-5 is designed to be heavily laden with chemicals like naphthalene, a chemical on the Safe Drinking Water Act list. But because it is a UVCB, the precise mixture is unknown or variable and therefore not reported.

We can get a glimpse into the most abundant components of these UCVBs because some Safety Data Sheets for the UVCBs list those constituents. For example, the ExxonMobil’s SDS for their product “Solvent Naphtha H” is 100% 64742-94-5, but it also lists some components:

Another maker of a 100% 64742-94-5 product, Monument Chemical, provides this list:

Safety Data Sheets from other companies for products reported as 100% 64742-94-5 either list no component chemicals or deviations from these lists (for example, see Shell’s product.) 

It is worth noting that many of the chemicals in these SDS are never reported directly in FracFocus. Remember, this product is a solvent and therefore designed to be composed of aromatics. In fact, Exxon’s product description sheet reports at least 98% aromatic content, even though Exxon’s three SDS components account for, at most, a little more than 50% of the whole mixture. Although we cannot know for sure, whenever 64742-94-5 is used, a significant portion of its mass is likely composed of these aromatics but they are hidden by the UVCB CAS number.

We can start to see what might be missing from UVCB labeling if we make the simple assumption that the Exxon SDS is representative of the 64742-94-5 used across FracFocus. That is, for every use of 64742-94-5, naphthalene comprises 0 to 14% of its mass. Considering that the currently reported mass of 64742-94-5 used is 69,100,000 pounds, we find that the amount that this one distillate adds to the directly reported mass of its chemical components is substantial:

Like produced water, it is difficult to directly identify the components of UVCB chemicals. The labels they are given identify rough characteristics but don’t reveal the details we need to assess environmental and health risks.

Conclusion

There is no doubt that FracFocus, as it exists now, is more useful to the public than no disclosure at all. From it, we have learned that hazardous chemicals regulated in other industries are commonly used in large quantities throughout the fracking industry without the same oversight. We’ve seen that despite the contentious nature of the use of trade secret chemicals, the practice continues to increase. We’ve learned that the number of chemicals used in fracking is over 1,300, many of which are virtually unstudied for their environmental and health effects, and the list continues to grow. And we can use FracFocus to examine some of the important chemicals used near specific sites, like homes or schools.

In spite of that, much of what the industry injects remains murky to the public because of the holes that exist in FracFocus. Those of us looking to understand potential health and environmental consequences of fracking must come to grips with these partial disclosures. And we should be suspicious of disclosure “improvements” that don’t address these gaping holes.